The CFTC's Division of Market Oversight on Oct. 5 published Letter 26-29, giving U.S. designated contract markets a fast-track route to remove expiration dates from existing perpetual-style broad-based stock-index futures.

The relief responds to a request from Coinbase Derivatives but applies to any DCM with qualifying contracts. It waives the standard 10-business-day waiting period for amendments, letting changes take effect once the letter's conditions are satisfied. Staff said they will not seek or impose a stay of those amendments under their delegated authority.

What does the letter actually change?

Perpetual-style equity-index products listed by Coinbase Derivatives carry expirations as far out as 25 years while already using periodic funding to track the underlying index. Removing those expirations erases the last structural distinction between these instruments and true perpetuals.

The relief permits no other material contract changes. Funding, margin, position-limit and reporting requirements stay in force. Staff warned that altering terms on contracts with open positions can move prices and create gains or losses without any change in market fundamentals.

What conditions must exchanges meet?

Before converting, a DCM must:

• Solicit feedback from holders about possible adverse effects
• Provide at least five calendar days' notice
• Allow positions to close under the existing terms
• Disclose the risks of the amendment

The exchange then files under Regulation 40.6(a) or 40.5, notifies the division that it will rely on the relief, certifies compliance and identifies the affected contracts. Eligibility covers only existing perpetual-style products tied to broad-based security indices, and the notice window extends to customers trading through intermediaries.

How does this fit the CFTC's earlier work?

Letter 26-29 mirrors the June digital-commodity conversion relief in Letter 26-19, requested by Coinbase Derivatives and Bitnomial. That earlier letter imposed the same five-day notice and expiration-only conditions but covered digital commodities and expired June 30.

The immediate precedent for the equity move is Kalshi's US500 perpetual submission. Kalshi filed for review under Regulation 40.3 on Aug. 18; staff deemed the contract approved Oct. 2.

Why is the broader classification fight still open?

CME announced a legal challenge in June, arguing in its D.C. district court complaint that crypto perpetuals are swaps, not futures, because they lack a fixed delivery date and rely on periodic payments. The CFTC's May 29 order took the opposite view, approving Kalshi's bitcoin perpetual as a futures contract.

Classification shapes collateral treatment. Futures accounts place customer margin and positions under CFTC futures rules, while cleared swaps use a segregation regime in which operational shortfalls, including theft, can still force customers to share losses pro rata.

What is the shelf life of the relief?

The letter binds only the issuing division, not the full commission. Its no-action positions expire Oct. 20, 2026. Coinbase Derivatives' roster — AI10, China10, Defense10, Tech100 and US500 — illustrates the set of contracts now eligible for conversion under the framework.